On July 1, 2026, Cal/OSHA took another step toward implementing a California variation of federal OSHA’s “worker walkaround rule”1 by posting proposed modifications to the proposed text and providing a narrow 15-day period for public comment, through July 16, 2026.
This action follows a previous comment period on the initial proposal and a public hearing conducted on April 1, 2026. The initial proposal raised concerns both because of its timing and substantial differences from the federal rule. While Cal/OSHA is now pursuing a regular rulemaking process,2 it has not to date responded to public comments questioning the agency’s rationale for the rule. Specifically, in its Initial Statement of Reasons (ISOR) for the proposal, the agency asserted that it is required by Labor Code § 50.7(d) to take “all steps necessary to prevent withdrawal of approval for the state plan by the Federal Government.” Yet there is no data or evidence to suggest that the federal government is currently